Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

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michaelotal
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Joined: Thu Mar 05, 2015 3:39 am

Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by michaelotal » Mon Aug 06, 2018 3:08 am

Hi (and apologies for cross-posting)! I would greatly welcome advice and thoughts on an issue I have been analysing, and have a block on seeing clearly the best way forwards.

The context is that I am a US / UK dual-national residing in Spain for six years in the portfolio accumulation stage. I have been following a long-term buy-and-hold low-cost whole market index ETF portfolio, making maximum use of tax-advantaged 401k and IRA accounts as well a brokerage account with Schwab, Fidelity and TD Ameritrade. I have a simple target asset allocation which seeks to balance US and rest-of-the-world exposure, with a strong but reducing leaning towards equities as my wife and I have some rental and business income :

Bonds / US: 10%
Bonds / Global ex-US: 10%
Stocks / Global developed ex-US: 30%
Stocks / Emerg Markets: 10%
Stocks / US: 40%

We do not have plans to live in the USA and I have a concern about the risk of concentrating the overwhelming majority of our financial investment assets in USD-denominated funds in US-based financial institutions. This concern has been heightened by certain recent unexpected geopolitical events, specifically the Brexit referendum wiping off 20%of the value of our sterling assets, and also Trump being elected and then initiating trade wars. While it seems almost unthinkable that anything could happen which would radically reduce access to or the value of the holdings in these three huge US companies in particular, as things stand it would take one black swan event to jeopardise our retirement livelihood. And in the interim, it seems preferable to reduce the concern of this occurring, if only to sleep easy at night

My thought on reducing the risk in this area was to start to balance the USD / US holdings with Euro-denominated funds held by a European financial institution.

My research indicated that DEGIRO offers the lowest institutional costs, selecting their Custody account as I do not favour the lending of my ETFs to lower the fees. (I ruled out Interactive Brokers because while it has a European operation, its headquarters is in the USA. I also ruled out UK-institutions as we have no plans to live in the UK and do no seek to increase our GBP holdings)

For ETFs, I wanted to try to replicate the above asset allocation, with the requirements that the funds are (1) physical not synthetic, (2) EUR-denominated, (3) low-cost, (4) currency-hedged, (5) accumulating and (6) provided by a European institution. For my research, I used the justETF screener (https://www.justetf.com/uk/find-etf.html).

It was not possible to find exactly what I was looking for as there seem to be no ETFs which match all requirements and would give me the geographical coverage I am seeking, however my initial conclusion was the the following two ETFs offer the closest match:

iShares Global Aggregate Bond UCITS ETF EUR Hedged (Acc) (Ticker: A2H6ZT; ISIN: IE00BDBRDM35; fees: 0.10%)
Xtrackers MSCI AC World Index UCITS ETF 1C (Ticker: A1W8SB; ISIN: IE00BGHQ0G80; fees: 0.40%)

My requirements analysis is as follows:
Both funds are physical, accumulating and EUR-denominated
The iShares bond ETF has good global coverage, good fees (for Europe, a bit high compared to the USA) and is currency-hedged. On the other hand, the fund is new (November 2017) and Blackrock is a US company, albeit one with a huge presence globally.
The Xtrackers equity ETF has good global coverage and is provided by a European company. However there is no hedging, the costs are high compared to US-based alternatives, the fund is quite new (2014) and seems quite small (€254m). Lastly, I am not familiar with Xtrackers / Deutsche Asset Management’s reputation in the same way as I am with my other ETF providers.

So, context established, the specific areas where I would very much appreciate comments, suggestions and recommendations are as follows:

The merits / demerits of the risk analysis that is prompting me towards a non-US owned financial institution and EUR-denominated ETFs which will have somewhat higher fees than their US-owned alternatives.
The merits / demerits of Degiro as an institution and any non-US owned alternative institutions I may have missed or need to reconsider. (I have read up some recent critiques of Degiro and their responses, however it is difficult as a non-financial professional to reach a final conclusion on opposing arguments.
The merits / demerits of the two ETFs selected and any alternatives I may have missed or need to reconsider.

Many thanks in anticipation!

TedSwippet
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Joined: Mon Jun 04, 2007 4:19 pm

Re: Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by TedSwippet » Mon Aug 06, 2018 3:38 am

Hello.
michaelotal wrote:
Mon Aug 06, 2018 3:08 am
The context is that I am a US / UK dual-national residing in Spain for six years in the portfolio accumulation stage. ... My thought on reducing the risk in this area was to start to balance the USD / US holdings with Euro-denominated funds held by a European financial institution.
My guess here is that you are not aware of the the US's protectionist PFIC tax rules? All of the ETFs you are considering would be subject to this punitive US tax, at levels that would more than destroy any usefulness you might obtain from them.

As a US citizen, if you want to used mutual funds or ETFs you are in effect trapped by the combination of US tax rules and the US's citizenship-based tax regime into only investing through US domiciled ones. (You already have dual citizenship so you could reasonably seamlessly escape this by renouncing US citizenship, but that might not be in your life-plan.)

Using funds with a non-US denomination currency won't actually solve your perceived problem, I don't think. The domicile of and denomination currency of funds are immaterial to long term performance. What matters is the domicile and currency of the things that the fund holds.

If you think the long term outlook for the USD is poor, you should buy ETFs or funds that invest in non-USD assets, but these can -- and for you, should -- be US domiciled and USD denominated.

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BeBH65
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Re: Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by BeBH65 » Mon Aug 06, 2018 4:02 am

Related to the currency topic: please have a look at our wiki page Base_currency_vs._trading_currency_vs._currency_of_the_underlying_asset.

We also have a page on Tax_issues. Please pay special attention as US national living outside of the USA.
BeBH65. (only an investment enthusiast, not a financial adviser, perform your due diligence).

Valuethinker
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Joined: Fri May 11, 2007 11:07 am

Re: Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by Valuethinker » Mon Aug 06, 2018 4:54 am

michaelotal wrote:
Mon Aug 06, 2018 3:08 am
Hi (and apologies for cross-posting)! I would greatly welcome advice and thoughts on an issue I have been analysing, and have a block on seeing clearly the best way forwards.

The context is that I am a US / UK dual-national residing in Spain for six years in the portfolio accumulation stage. I have been following a long-term buy-and-hold low-cost whole market index ETF portfolio, making maximum use of tax-advantaged 401k and IRA accounts as well a brokerage account with Schwab, Fidelity and TD Ameritrade. I have a simple target asset allocation which seeks to balance US and rest-of-the-world exposure, with a strong but reducing leaning towards equities as my wife and I have some rental and business income :

Bonds / US: 10%
Bonds / Global ex-US: 10%
Stocks / Global developed ex-US: 30%
Stocks / Emerg Markets: 10%
Stocks / US: 40%

We do not have plans to live in the USA and I have a concern about the risk of concentrating the overwhelming majority of our financial investment assets in USD-denominated funds in US-based financial institutions. This concern has been heightened by certain recent unexpected geopolitical events, specifically the Brexit referendum wiping off 20%of the value of our sterling assets, and also Trump being elected and then initiating trade wars. While it seems almost unthinkable that anything could happen which would radically reduce access to or the value of the holdings in these three huge US companies in particular, as things stand it would take one black swan event to jeopardise our retirement livelihood. And in the interim, it seems preferable to reduce the concern of this occurring, if only to sleep easy at night
As per Ted Swippet this is all fairly irrelevant.

Your issue is tax. As a US national, you have to hold funds which meet PFIC. Unfortunately new EU financial services legislation means most (all?) platforms have stopped selling them to EU residents. If you have a US account, hold onto it for dear life.

US citizens living in EU are basically stuffed. They have to hold US funds, but the platforms are blocking them buying those ETFs.

As per others, currency of denomination is irrelevant. What matters is currency of exposure.

Geopolitical analysis never gives you a correct view of currencies or market returns. I might make any exception for some Emerging Markets, but then, Brazil rallied and turned into the top performing market. Russia, too. Turkey looks to me like a basket case at the moment but no doubt it, too, will turn on a dime at some point (the market moves before it becomes clear there is good news - it's smarter than we are as individuals, being the sum total of all knowledge of a situation).

Ignore the political noise, set an asset allocation and stick with it. That is what has worked for investors for decades. It's very hard to make a case for anything than global market weighting for your equities. Yes that means over 50% exposure to US companies, because that is what the market thinks the correct value is for those companies, discounting all economic and political factors.

How you sort out the US tax implications of your UK holdings, I do not know. Specialized tax advice, I would guess.

Note also you have US estate tax to worry about (if you are planning to leave an inheritance). I believe for assets above $60k (but I am not sure) it appears to depend upon treaties with individual countries (not the EU as a whole).

On bonds we tend to favour currency hedged funds, here. Then the reporting currency (denomination) matters because the fund uses derivatives (futures, options, swaps) to hedge back into the currency of denomination (= currency of exposure, therefore). But again you have US tax issues, so if you can find an Intermediate Term US Treasury Bond fund, I would stick with it. You are fully exposed on USD/ EUR currency moves, but conversely US Treasury Bonds pay nearly 3% yield-- not too shabby when the German ones pay 0.5% or less. And if Italy does do the big exit the Euro and restructure (and the yield on Italian government bonds is 1-1.5% higher than German, last I checked, so the market thinks this *could* happen) then you will be spared that.

TedSwippet
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Re: Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by TedSwippet » Mon Aug 06, 2018 6:04 am

Valuethinker wrote:
Mon Aug 06, 2018 4:54 am
Note also you have US estate tax to worry about (if you are planning to leave an inheritance). I believe for assets above $60k (but I am not sure) it appears to depend upon treaties with individual countries (not the EU as a whole).
The OP is a US citizen, so US estate taxes shouldn't be a massive worry. This $60k limit is the exemption for non-resident aliens in countries without a US estate tax treaty, but US citizens get a currently around $11MM exemption no matter whether or not they are US residents.

There can be some fiddly rules where property passes from a US citizen to a non-US citizen spouse, for example no unlimited marital exemption. And also some fiddly US gift tax rules in the same circumstances. But not the outrageous and confiscatory 40%-of-everything-over-$60k meted out to some US non-resident aliens with the poor judgement to die while holding US situated assets.

michaelotal
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Joined: Thu Mar 05, 2015 3:39 am

Re: Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by michaelotal » Fri Aug 10, 2018 6:57 pm

Thank you all for this very useful input.

I hadn’t heard of the PFIC rules, and now I have had a chance to read up on them, I am impressed by their savagery. There are a couple of follow-on points here which I am seeking to explore -- if anyone is able to comment on, I would be grateful.

1) My wife is not a US citizen (a “non-resident alien”) nor currently does she have a Green Card, however we do submit our taxes as “Married filing jointly”. Nonetheless, she appears to not be a “U.S. Person” (Legal Information Institute), and therefore not covered by the PFIC rules (“ a U.S. person that is a direct or indirect shareholder of a PFIC must file Form 8621”, Expat Tax Professionals). So by this definition, if the assets in question were in her name only, then they would be outside the scope of the PFIC rules.

On the other hand, as we have “married filing jointly” status, the “election under IRC § 6013(g) affords a nonresident alien married to a U.S. citizen or resident alien the ability to be treated as a U.S. resident for purposes of Chapter 1 and Chapter 24 and sections 6012, 6013, 6072 and 6091 of the Code for the entire taxable year” (IRS). So this would suggest that she is covered by the PFIC rules assuming that the PFIC rules feature in these parts of the Code. And Thun Financial takes this view.

This being the case, then I understand that we would need to keep total assets in the PFICs below $50,000 to avoid the reporting requirement

2) Inheritance tax is indeed a concern as I understand that the threshold for tax free inheritance for the non-resident alien spouse is as low as $60k. I have a whole follow-on project to explore this area fully including looking into Qualifying Domestic Trusts QDOT. If anyone has already researched this area, I would appreciate any pointers.

Many thanks!

https://www.law.cornell.edu/uscode/text/22/6010
https://www.expattaxprofessionals.com/F ... -Reporting
https://www.irs.gov/pub/int_practice_un ... _02_09.PDF
https://thunfinancial.com/home/american ... s-couples/
https://www.investopedia.com/terms/q/qu ... -trust.asp

TedSwippet
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Re: Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by TedSwippet » Sat Aug 11, 2018 3:36 am

michaelotal wrote:
Fri Aug 10, 2018 6:57 pm
On the other hand, as we have “married filing jointly” ... So this would suggest that she is covered by the PFIC rules assuming that the PFIC rules feature in these parts of the Code. And Thun Financial takes this view.
This, unfortunately. By electing MFJ your non-US citizen wife is dragged into the entire US tax minefield, and as you are now discovering, it is a very uncomfortable place for people who live outside the US. Consider changing to MFS and extricating your wife. She will then be able to invest freely in local and non-US assets without being punished at every turn by US tax rules and restrictions.
michaelotal wrote:
Fri Aug 10, 2018 6:57 pm
This being the case, then I understand that we would need to keep total assets in the PFICs below $50,000 to avoid the reporting requirement.
This de miminis limit only gets you out of painful PFIC annual reporting. If or when you sell the investments or receive dividends or other distributions from them, you are still subject to the full ferocity of the PFIC tax rules. More from PwC here.

The only way out here for you personally is to entirely avoid all non-US domiciled investments. Your wife must either do the same, or if you change to filing MFS she then becomes free to invest as she wishes.

It's really nasty, isn't it?

michaelotal
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Re: Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by michaelotal » Mon Aug 13, 2018 6:26 pm

It is nasty Ted - as I was reading up on the PFIC rules I was reminded of Alan Arkin's Yossarian when having Catch-22 explained to him for the first time, whistling then responding, "That's quite some catch!".

Transitioning my spouse from MFJ to MFS requires a considerable amount of analysis as to the impact on the cost / benefit equation. Particularly in a context where she already accesses and benefits from world-leading US financial institutions and products. I take the point that doing so could enable her to invest in non-US domiciled passive assets and thereby address a low-likelihood / high impact risk I perceive, however the disadvantages of the change may amount to more than the benefit of this risk minimisation. The Boglehead page Passively managing individual stocks points towards another approach to be considered.


Putting aside the intended European-domiciled EUR assets in a European brokerage account, the new-found awareness of PFIC made me wonder about our existing Spanish private pension arrangement, which is a with the passive robo-investing institution Indexa Capital.

Passive pension funds appeared to be in-scope for the PFIC regulations, however as the PWC guidance clarifies, an "exception applies for any beneficiary of, participant in, a plan, trust, scheme, or other arrangement that is treated as a foreign pension fund if an income tax treaty states that any income from the fund is only taxed when it is paid to the shareholder".

Article 20 Section 1 (a) of the USA - Spain tax treaty states that "pensions and other similar remuneration derived and beneficially owned by aresident of a Contracting State in consideration of past employment shall be taxable only in that State"

My reading of this is that a passively-based pension scheme in Spain is outside the scope of the PFIC regulations.

If anyone has any direct experience or different understanding of this (either in Spain or another country with a similar treaty), please share.

Many thanks!

https://www.bogleheads.org/wiki/Passive ... ual_stocks
https://www.pwc.com/gx/en/services/peop ... ptions.pdf
https://www.irs.gov/pub/irs-trty/spain.pdf

TedSwippet
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Re: Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by TedSwippet » Tue Aug 14, 2018 2:46 am

michaelotal wrote:
Mon Aug 13, 2018 6:26 pm
Article 20 Section 1 (a) of the USA - Spain tax treaty states that "pensions and other similar remuneration derived and beneficially owned by aresident of a Contracting State in consideration of past employment shall be taxable only in that State"
The US also has a Catch-22 written into its treaties. In the case of Spain it lurks in Article 1 Paragraph 3, which states that "Notwithstanding any provision of the Convention except paragraph 4, a Contracting State may tax its residents (as determined under Article 4 (Residence)), and by reason of citizenship may tax its citizens, as if the Convention had not come into effect." Paragraph 4 exempts Article 20 Paragraph 4, but not Article 20 Paragraph 1.

The effect here seems to be that the US and Spain may both tax pension distributions, with the US having to provide credit for Spanish taxes so as to avoid double-taxation. I don't know, though, whether this means that the US simply looks through Spanish pensions. My sense is that no, it does not mean that, and so PFIC wouldn't be an issue in them, but as you can see, US tax treaties are slippery, malleable, and porous, and I'm no expert in reading them, so maybe take that for what it's worth. I'm just a random bloke on the internet.

You picked up on it earlier, but just to reiterate, the other thing to bear in mind is that the US has no estate or gift tax treaty with Spain, meaning that anything your wife holds in the US beyond a miserly $60k could be at risk from US estate tax.

This is "could be" because the application of the estate tax depends on who is the beneficiary, and the $60k exemption is relaxed only in the specific case of a US citizen spouse recipient. There is a summary of how US estate taxes hit US non-resident aliens in this table. The numbers may be a little different (higher) in a few cases for 2018, but the rules haven't changed. And the 2017 tax changes did not raise the pitiful $60k exemption.

michaelotal
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Joined: Thu Mar 05, 2015 3:39 am

Re: Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by michaelotal » Mon Aug 27, 2018 7:58 pm

Thanks for highlighting the Article 1 Paragraph 3 caveat Ted - I hadn't noticed that connection with Article 20.

I had expected that the US would want to tax pension distributions after crediting their taxation in Spain, and it was really the the applicability of the PFIC regulations specifically to my passive invesments holding pension account which was the concern. I feel that there remains an ambiguity here however my reading of the PWC analysis of the final regulations is reassuring enough to continue contributing into the account.


Moving on to estate tax, thanks for sending the link to Clark and Skatoff pdf. It looks like it should be a useful summary, however is there a typo in it? On the Estate tax table, in the box relating to inheritances from a US citizen (me) to a non-resident alien (my wife and children currently), there is no mention of the $60k threshold for assets held in the US, which I heard about and to which I think you referred. Would you say my reading of the table is incorrect....or is the table incomplete?

Moreover, am I right in thinking that if I can arrange Green Cards for my wife and kids, then this $60k threshold disappears?

Thanks

Andrew



https://www.pwc.com/gx/en/services/peop ... ptions.pdf

https://www.clarkskatoff.com/files/Non% ... 202017.pdf

TedSwippet
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Re: Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by TedSwippet » Tue Aug 28, 2018 5:58 am

michaelotal wrote:
Mon Aug 27, 2018 7:58 pm
Moving on to estate tax, thanks for sending the link to Clark and Skatoff pdf. It looks like it should be a useful summary, however is there a typo in it? On the Estate tax table, in the box relating to inheritances from a US citizen (me) to a non-resident alien (my wife and children currently), there is no mention of the $60k threshold for assets held in the US, which I heard about and to which I think you referred. Would you say my reading of the table is incorrect....or is the table incomplete?
The table looks as expected to me. The US's estate tax falls on the US situated estate of the deceased, before distribution to recipients. So as a US citizen you get the standard $11MM (as of 2018) exemption. Your wife however only gets a $60k exemption, because she is not a US citizen or resident alien, but there is a specific exception to that for assets passing to a US citizen spouse (you).

You can readily see how this could create some ridiculously unpalateable outcomes. Suppose you own $1MM in US assets, and you (US citizen) and your wife (non-US citizen) both have wills saying that assets pass to your respective spouse if still alive, otherwise to your (non-US citizen) children. That's a pretty common setup in wills.

If your wife dies before you do, your children inherit the full $1MM. If the order of deaths is reversed, your children only inherit a shade above $600k, with on the order of $400k disappearing to the US in wasted deadweight estate taxes, because after your death a non-US citizen now owns this $1MM of US situated assets. This last case can be a particular problem with illiquid assets, including 401ks and IRAs, since with these there may be little or no opportunity to remove them from the US between deaths. (There is something called a QDOT that could alleviate things, but it is restrictive, comes with a price, and in effect involves leaving all the assets captive in the US while only really deferring the eventual and rapacious US estate tax. Generally better avoided where possible.)
michaelotal wrote:
Mon Aug 27, 2018 7:58 pm
Moreover, am I right in thinking that if I can arrange Green Cards for my wife and kids, then this $60k threshold disappears?
The first thing to check would be whether or not your children are already US citizens. They might be, since US citizenship (like a hereditary disease) can be passed down from a parent if the right US residency timing conditions are met. However, your children are probably not currently the ones in your family with the potential to hold much in the way of US situated assets.

Beyond this, getting green cards may be fiddly unless you plan to actually move to the US once you have them. It is a lengthy and rather expensive process, and even once obtained, if not actually living in the US they can be considered effectively invalid (in actuality they fall into an odd limbo state, a sort-of 'Schrodinger's resident status', neither valid nor invalid for US immigration purposes until some determination by an immigration judge or until you officially surrender them, but of course always operative for US tax purposes).

Plus, of course, gaining green cards for you wife and family will instantly cast them all into the wretched fiery pit of full US tax compliance with the IRS, something that you have already run into as problematic, and something that most sensible non-US persons are generally extremely keen to avoid.

michaelotal
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Re: Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by michaelotal » Thu Nov 08, 2018 10:19 am

Ted thanks for your feedback on this.

I am pretty sure that kids are not US citizens, and I have heard they cannot get green cards now unless moving there which is not planned.

Based on your feedback and my own research so far, I have developed the following scenario analysis:


Scenario 1: US citizen spouse dies, non-resident alien spouse survives for a long time
No problem if US citizen’s estate < $11m; estate passes 100% to NRA wife or mix of NRA wife and NRA kids
Plan: estate recipients drawdown US sited assets in order to reach level below own $60k estate tax threshold. Alternatively, if assets can be sold without loss, then liquidating US-sited assets avoids the risk of NRA estate recipient(s) dying $60k threshold reached
Issue: ?possible restrictions on NRA spouse in investing in non-US passive assets if still in US tax system because of married filing jointly.

Scenario 2: US citizen spouse dies, non-resident alien spouse dies shortly after
Problem: all US citizen’s estate passes to NRA spouse whose US-sited estate assets passing to NRA kids taxed heavily after threshold of $60k.
Mitigation for US citizen’s estate:
Reduce US citizen’s US-sited assets, BUT PFIC prevents non-US passive assets
Transfer US citizen’s assets to QDOT, BUT QDOTs are reportedly problematic
Transfer US citizen’s assets directly to kids to get high value exclusion BUT creates liability for Spanish inheritance tax
Mitigation for surviving NRA spouse’s estate
Reduce NRA’s spouse US-sited assets, BUT PFIC prevents non-US passive assets for Married Filing Jointly NRA spouse
Mitigation: remove NRA spouse from MFJ tax return BUT possible (unresearched) increase in tax liability for change to Head of Household tax return. ALSO possible (unresearched) loss of access for NRA spouse to own 401k and IRAs, although recent PRIIPs restrictions have made investments from Europe in US-domiciled 401ks more difficult.

Scenario 3: US citizen and NRA spouse die together
No problem for US citizen’s estate passing to NRA kids if under ?$5.5m exclusion amount
Problem for NRA spouse US-cited assets over $60k threshold passing to NRA kids being taxed heavily
Mitigation: as per scenario 2


If you Ted - or anyone else - can see any errors or omissions in this analysis, please let me know.

Many thanks!

DJN
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Re: Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by DJN » Thu Nov 08, 2018 10:58 am

Hi,
I do not want to complicate your already very complicated situation however it might be helpful. I know nothing about Spanish tax. I don't believe that you mentioned the domicile of your wife and if she has a non Spanish domicile then it might be interesting to see if there is a non domicile status available for her which might have tax advantages for you were you to keep your assets in an account offshore in her name. Long shot, but one which works for me in another domicile, a Spanish tax specialist might assist.
good luck
DJN

michaelotal
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Re: Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by michaelotal » Sun Nov 11, 2018 1:22 am

Thanks DJN - we both have Spanish domicile and will do at least until our youngest child finishes school in ~14 years. thereafter, we may well look to changing our domicile, however before that I hope to optimise as far as possible our estate planning for this period.

DJN
Posts: 163
Joined: Mon Nov 20, 2017 12:30 am

Re: Euro-denominated ETFs in European institution to balance USD-denominated ETFs in US institutions

Post by DJN » Sun Nov 11, 2018 1:55 am

Hi,
Obviously domicile for tax purposes can be tricky, however it can also be advantageous. If your wife was born outside of Spain then this might establish her tax domicile somewhere else? Then there might be an advantage? Domicile is usually set by the domicile of the father. It's also tricky to change domicile. I am not a lawyer!
DJN

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